Perkins v. Astrue, 648 F.3d 892

Perkins applied for disability benefits; ALJ denied, finding she could perform past work.
Appeals Council denied review; district court affirmed the ALJ’s decision.
Perkins has a work history including lace cutting, beauty shop ownership, and a nonprofit director role; last full-time work ended in 2005.
Medical history includes fibromyalgia, hypertension, GERD, COPD, depression, anxiety; diagnosed fibromyalgia by pain specialists; cervical spine fusion in 1995.
ALJ found impairments well controlled with medication and that no impairment met or equaled a listed disability.
Perkins challenged the ALJ’s treatment of the treating physician’s opinions, fibromyalgia assessment, credibility, vocational hypotheticals, and potential bias; court upheld the ALJ’s decision based on substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to treating physician	Meidl's opinions should be controlling.	Disability determinations reserved to the Commissioner; inconsistent or unsupported opinions may be discounted.	ALJ properly discounted some opinions; substantial evidence supports discount.
Fibromyalgia severity evaluation	ALJ failed to apply fibromyalgia policies properly.	ALJ acknowledged diagnosis and still found impairment not disabling.	No reversible error; substantial evidence supports non-disabling finding.
Credibility and Polaski factors	ALJ neglected Polaski factors and credibility of statements.	ALJ discussed relevant Polaski factors and daily activities; credibility appropriately weighed.	ALJ’s credibility assessment upheld; substantial evidence supports determination.
Hypothetical to vocational expert	ALJ should include all limitations, including self-imposed ones, in the hypothetical.	Only supported limitations should be included; unsupported ones need not be included.	Hypothetical properly limited to supported impairments; no error in VE testimony.
ALJ bias	ALJ biased against claimants like Perkins; improper conduct at hearing.	No evidence of bias; statements were not so extreme as to show disqualifying bias.	No bias established; decision affirmed on substantial evidence.

Medhaug v. Astrue, 578 F.3d 805 (8th Cir. 2009) (treating-physician weight governed by consistency with record)
Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (substantial evidence standard; credibility and medical evidence interplay)
Jones v. Chater, 86 F.3d 823 (8th Cir. 1996) (pain testimony not automatically disabling)
Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (Polaski factors for evaluating credibility)
Hunt v. Massanari, 250 F.3d 622 (8th Cir. 2001) (hypothetical must reflect impairments supported by substantial evidence)
Davidson v. Astrue, 578 F.3d 838 (8th Cir. 2009) (evidence-based discounting of treating opinions permissible)
Heino v. Astrue, 578 F.3d 873 (8th Cir. 2009) (rejecting controlling weight for some treating opinions)
Brace v. Astrue, 578 F.3d 882 (8th Cir. 2009) (impairment controlled by treatment cannot be disabling)
Brown v. Astrue, 611 F.3d 941 (8th Cir. 2010) (impairment controllable by treatment cannot be disabling)